What happened
Consultation conclusions set the direction of the new permissions
On 26 May 2026, the Financial Services and the Treasury Bureau and the Securities and Futures Commission published conclusions after receiving 51 submissions. The market generally supported the policy direction. The proposed virtual-asset advisory regime will align with the scope of Type 4 advising on securities, while virtual-asset management will align with Type 9 asset management concepts.
The proposals remain at the legislative stage. The FSTB and SFC intend to finalise the AMLO amendments and introduce a bill in 2026. Commencement will be set later, with implementation timing taking account of the adjustment period needed by the market.
Regulator facts
The proposed commercial perimeter
Virtual-asset advisory
Covers business advice on acquiring or disposing of virtual assets and analyses or reports intended to facilitate those decisions, across communication channels.
Virtual-asset management
Covers discretionary management of a virtual-asset portfolio for another person, including funds and managed accounts, with no proposed de minimis threshold.
Financial resources
For management firms, the proposal is HK$100,000 liquid capital where no client assets are held; otherwise HK$5 million paid-up capital and HK$3 million liquid capital.
Custody design
Private funds may use qualified custodians globally, with robust controls proposed for cases where qualified custody is unavailable.
Who is affected
Advisers, managers and existing licensed groups should prepare early
The scope is relevant to businesses giving investment-style virtual-asset recommendations, publishing decision-oriented analysis as a service, or managing VA portfolios with discretion. Existing SFC licensed corporations, registered institutions, fund managers and groups building Hong Kong digital- asset propositions should compare their current permissions, client-asset model and personnel with the proposed standalone AMLO regimes.
The conclusions also keep active marketing to the Hong Kong public within the intended reach. Location and channel labels will therefore carry less weight than the substance of the service and the market being addressed.
What changes for the business
Advisory and management become distinct design decisions
A group offering research, recommendations and discretionary portfolios should separate those services in its product map. Each line needs its own client journey, mandate language, responsible people, conflicts controls and financial- resource analysis. A fund manager also needs a custody model that fits the assets and markets used, including the evidence supporting any self-custody component.
The authorities plan standalone AMLO licensing regimes that will succeed the current terms-and-conditions approach used for relevant existing intermediaries. The proposed transition uses a hard commencement, alongside an expedited application process for existing licensed or registered providers.
SKY7 view
Build the target licence file now, then anchor it to the bill
The direction is clear enough for commercial planning even though the final ordinance and commencement date are still pending. Groups can decide whether advisory, discretionary management or both belong in the Hong Kong model and start assembling the operating evidence: service definitions, client types, portfolio discretion, custody, responsible officers, governance and capital.
Existing licensed groups should also preserve the facts that may support the expedited route. The efficient sequence is to design against the conclusions, test the economics under the proposed financial-resource levels and update the file when the bill and detailed regulatory requirements are published.
What to do now
Prepare the business before legislation lands
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Split advice from discretion
Map every recommendation, research output, trade decision and portfolio mandate to the intended advisory or management perimeter.
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Model the applicant structure
Identify the Hong Kong entity, existing SFC statuses, responsible people and the financial resources required for the planned mix.
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Fix the custody architecture
Document qualified custodians, asset locations, control ownership and any exceptional self-custody use case.
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Track the legislative package
Update the plan when the bill, detailed rules, fees, application process and commencement date are published.
Primary evidence
Official sources
- FSTB and SFC announcement on the consultation conclusions
- Official VA advisory and management consultation conclusions
Sources checked .